loan repayment

Report
Loan RepaymentThe Buck Starts Where?
Dana Kelly & Anne Del Plato
Nelnet Loan Servicing
Agenda
 Exit Counseling – What’s New?
 Repayment Plans not Based on Income
 Income-Driven Repayment Plans
 Highlights and Examples
 Public Service Loan Forgiveness
EXIT COUNSELING
Topics Covered in Exits
 Seriousness and importance of federal student loan
repayment obligation, including summary of consequences
of loan default
 Review terms and conditions of student's federal loans,
including interest rates, grace periods and date first
payments are due
 Explain that borrower has right to prepay federal student
loans or accelerate repayment of the loans without penalty
Topics Covered in Exits
• Review debt-management strategies that can help borrower
repay loans, such as how to develop a realistic budget
• Effects of federal student loan consolidation on borrower's
loans, including total interest and fees, length of repayment,
monthly payments, and total payments and potential loss of
benefits
• Provide information about loan forgiveness and cancellation
options
• Provide information about education tax benefits that are
available to federal student loan borrowers
Topics Covered in Exits
• Provide borrower with information about various
resources available
– National Student Loan Data System (NSLDS) for access to
borrower’s federal education loan records including current loan
types and balances, assigned servicer, and other information
– Information about Federal Student Aid (FSA) Ombudsman at the
U.S. Department of Education
– Names and contact information of those borrower can contact with
questions about loan terms and conditions, and borrower rights
and responsibilities
– Contact information for the servicer of the borrower's federal
student loans
Information Collected
• Borrower's name, address and Social Security number
• Borrower's driver's license number and state of issuance,
if applicable
• Borrower's expected permanent address
• Name and address of borrower's current and/or expected
employer
• Name and address of the borrower's next of kin
• Names and addresses of two references for borrower
who live in the U.S
Changes as of March 2013
• Enhanced loan counseling modules on
StudentLoans.gov
– Entrance
– Financial Awareness
– Exits
Changes as of March 2013
• Borrower provided with preliminary repayment plan
eligibility information and estimated repayment
amounts via information on NSLDS
• Borrower has opportunity to select repayment plan
desired
• Repayment plan preference provided to borrower’s
federal loan servicer to facilitate that repayment plan
prior to the end of six-month grace period.
SERVICER OUTREACH
TO BORROWERS
Servicer Outreach to Borrowers
Nelnet Example
Correspondence regarding repayment plans via mail/e-mail
Counseling calls with borrowers to discuss payment plans
and Income-Driven options applicable to borrower’s situation
Information provide on online account at nelnet.com or
mobile website
Self-service borrower tools: iPhone/Droid/web-based
repayment calculator apps
Financial literacy materials & literature
Student webinars (Money Mondays)
LOAN REPAYMENT
Plans not Based on Income
 Standard Repayment
 Graduated Repayment
 Extended Repayment
 Alternative Repayment (DL only)
Standard Repayment
• Borrower will pay fixed amount: at least $50 each
month for up to 10 years
• Borrower will pay fixed amount: at least $50 each
month for up to 10 years
– Repayment period is shorter than it would be under any
other repayment plans
Graduated Repayment
• Beneficial if borrower’s income low when leaving
school but likely to steadily increase
• Payments start low and increase every two years
• Minimum payment = amount of interest that accrues
monthly for up to the maximum repayment period
• Maximum repayment period:
o 10 years for Subsidized, Unsubsidized, and PLUS loans
o 10-30 years for Consolidation loans depending on the
total loan indebtedness
Extended Repayment
• Borrower may choose this plan if (s)he did not have outstanding
balance on FFEL or Direct Loan as of 10/7/98. Must also have
more than $30,000 in outstanding FFEL Program loans or more
than $30,000 in outstanding Direct Loans.
• For example…
A borrower that has $35,000 in outstanding FFEL Program loans
and $10,000 in outstanding Direct Loans can choose the Extended
Plan for their FFEL loans, but not for their Direct Loans.
o Borrower may choose to make fixed or graduated monthly
payments
o Minimum payment of $50 for Fixed Extended
o Maximum repayment period is 25 years
Alternative Repayment
• DL Only
• May be used when terms and conditions of other repayment plans
are not adequate to accommodate borrower’s circumstances
• Borrower must provide evidence of exceptional circumstance
• Terms must be within the following restrictions:
o Maximum 30-year term
o Minimum payment of $5.00
o Payments cannot vary by more than 3x the smallest payment
• Four Direct Loan Alternative repayment plans:
o Alternative Fixed Payment
o Alternative Fixed Term
o Alternative Graduated
o Alternative Negative Amortization
INCOME SENSITIVE
REPAYMENT
Income Sensitive Repayment
• FFEL Only
• Lender-specific
• Scheduled monthly payment based on borrower’s
•
•
•
•
annual income
Payment amount increases or decreases based on
income change
Maximum repayment period is 10 years (except
consolidation loans)
Borrower must re-apply each year
Monthly payments may be increased for the remaining
term of the loan to compensate if the borrower receives
decreased payments under ISR
INCOME-BASED
REPAYMENT
What is IBR?
• Created by Congress under College Cost Reduction and
Access Act of 2007 (implementation date of 7/1/09)
• Ideal for individuals entering careers with relatively high
loan debt compared to starting salaries, such as:
–
–
–
–
Medicine
Law
Elementary/Secondary Education
Social Work
• Potential tool for individuals whose loans are in a
delinquent status
What is IBR?
• Lower Payments + Longer than standard 10 years to repay =
Paying more over the life of the loan
• Must have Partial Financial Hardship (PFH) to qualify
• Provides interest subsidy on subsidized loans for up to 3
years if IBR payment is less than accrued interest on those
loans*
• Provides forgiveness of remaining balance after 25 years
(300 eligible payments)
* IBR subsidy is for the amount of interest that the scheduled payment amount
does not cover. This differs from interest subsidy for deferments and other
periods where all of the interest is covered. All interest would be covered if
payment amount is $0.
Partial Financial Hardship (PFH)
Borrower’s annual
loan payment using
standard 10-year
repayment plan
>
15% of (borrower’s
Adjusted Gross
Income – 150% of
poverty line amount)
Based on income and family size
• Final rules effective 07/01/2010 allow for the PFH to be
determined based on the greater of either:
– The amount due at the time the loans entered repayment or
– The time the borrower or spouse requests the plan
INCOME CONTINGENT
REPAYMENT
What is ICR?
• Available for FDLP only
• Any DL borrower (other than a PLUS borrower) may
choose ICR
• Payment considers total DL debt + income and family
size
• Borrower pays all interest that accrues on loans.
Unpaid negative amortized interest up to the 10%
limit is capitalized
• Unpaid interest is capitalized annually
PAY AS YOU EARN
What is Pay As You Earn?
• The borrower must qualify for a PFH when initially
requesting this repayment plan
• Once the borrower has qualified for PAYE, updated AGI
and certified family size must be submitted annually to
recertify the PFH
• It is possible to remain in PAYE after initial qualifications,
even if borrower does not meet the PFH qualifications
for recertification
Pay As You Earn
• PFH calculated by taking the difference between AGI and
150% of the poverty level for the borrower's state/family size,
and will not exceed 10% of the discretionary income.
• Borrowers with no taxable income or who have an AGI less
than 150% of poverty level for their state and family size
qualify for a zero PFH.
• If loan in another income-driven repayment plan or alternate
repayment plan, eligible loans need to be moved into
standard repayment plan prior to applying for PAYE.
Pay As You Earn
• If current income-driven repayment plan is IBR, borrower will
be required to make monthly payment under expeditedstandard repayment schedule or reduced pay forbearance
after exiting IBR and before PAYE plan can be applied.
• If the borrower does not qualify for PAYE, previous repayment
plan should be maintained.
THE APPLICATION PROCESS
Income Documentation
• Borrower must submit income documentation when
•
•
applying
Eligibility (IBR & Pay As You Earn) and payment
amount (all three plans) usually based on borrower’s
AGI
Borrower may document AGI through
– The electronic application (uses same method as IRS data
retrieval tool for the FAFSA to document AGI)
– A paper copy of a 1040, 1040A, or 1040EZ (signed or
unsigned)
– An IRS Tax Return Transcript
Income Documentation
• If AGI not available or does not reasonably reflect
current income, borrower can submit alternative
documentation of income (ADOI)
• Borrowers must provide documentation of all taxable
income, e.g., pay stubs, unemployment benefits, etc.
– Loan holder estimates annual taxable income based on this
documentation
• Borrowers do not provide documentation of untaxed
income, such as Supplemental Security Income or
welfare
ADOI Additional Considerations
• Borrowers who use electronic application must follow
•
up with their loan holder and send in documentation
It is often difficult to know how frequently the borrower
receives income based only on documentation
– Is it twice per week or twice per month?
– Loan holders have tended to request varying amounts of
documentation to ensure an accurate determination
– Direct Loan ADOI form asks for frequency of pay
– Soon, new form for both Direct Loans and FFEL will ask for
one piece of documentation per source of income and for
borrower to write frequency of pay on the documentation
ADOI Additional Considerations
• Projected annual income using ADOI may be
higher than borrower’s AGI will be
– Loan holders cannot subtract out “above the line
deductions” to income that a borrower may take when
filing a tax return, which would lower AGI
• Loan holders might only exclude pre-tax
deductions from pay if they are obvious
– Loan holders can accept a signed statement from the
borrower explaining pre-tax deductions
• Borrowers may not have held the job for the entire
year, but loan holders project income to cover a
12-month period
Recertifying Income and Family Size
• Under all three plans, borrowers are required to submit
updated income documentation annually
• Failure to submit documentation in a timely manner will
lead to:
– Monthly payment amount that is what it would have been on
10-year standard repayment plan (non- income-based ) , &
– Interest capitalization
• Borrowers must also annually certify their family size or a
family size of one will be used
Recertifying Income and Family Size
• The reevaluation date is based on when the borrower
initially entered the plan (anniversary date)
• Borrower can also submit documentation early, if their
circumstances have changed, to receive a lower payment
amount. This changes their anniversary date
• Borrowers can use the electronic application to recertify
their income and family size
Recertifying Income and Family Size
*NEW* - Negotiated Rulemaking 2012
• Borrowers will receive educational notices about their IDR plan
• Borrowers will receive notice of deadline by which they must
submit income documentation & consequences of failing to do so
• Borrowers submitting income documentation within 10 days of
deadline will have current payment amount maintained until
income documentation processed & new payment amount
calculated
– Loan holder’s inability to determine a borrower’s new payment amount
by borrower’s anniversary date will no longer result in automatically
increased payment amounts and capitalization of all outstanding
interest
• Final regulations published: 11/1/ 2012
Electronic Income-Driven Application
• Can be used by borrowers with ED-held loans (Direct or FFEL)
• Can be used by borrowers with commercially held FFEL loans
•
•
•
•
serviced by entity that also services ED-held loans
– Hope to cover all commercially held FFEL loans soon
Hosted on the StudentLoan.gov. Borrowers can access
application directly or through loan servicers’ websites
Uses IRS Data Retrieval Tool that is used on the FAFSA Retrieves the most recent tax information from two most recently
completed tax years
Electronically transmits application to loan servicer—no followup necessary unless AGI is unavailable or borrower wants to
submit alternative documentation of income
Can be used for initial applications or annual reevaluations
Electronic Application IRS interface
Electronic Application Review
Electronic application confirmation
Paper Income-Driven Application
• Available for borrowers who cannot or do not wish
to use electronic application
• For Direct Loans, includes Repayment Plan
Selection Form and (if applicable) Alternative
Documentation of Income Form
• For FFEL Program, includes FFEL IBR Request
form and (and applicable) Alternative
Documentation of Income Form
HIGHLIGHTS:
Income-Driven Plans
Recap: Income-Driven Plans
Three Main Plans
– Income-Contingent Repayment Plan (ICR)–1994
• Direct Loan Program only
• More information available at StudentAid.gov/ICR
– Income-Based Repayment Plan (IBR)– 2009
• Available in both the Direct Loan and FFEL Program
• More information available at StudentAid.gov/IBR
– Pay As You Earn Plan– 2012
• Direct Loan Program only
• For new borrowers in FY 2008 who receive new loans in FY 2012
• Modeled on IBR, incorporating statutory IBR changes scheduled to
•
•
take effect for new borrowers in 2014
More information available at StudentAid.gov/PayAsYouEarn
12/7 Federal Register provided implementation date of 12/21/12
Eligible Borrowers
• ICR
– Direct Loan borrowers with eligible loans
• IBR
– Direct Loan and FFEL Program borrowers with eligible loans, and
– Their payments would be lower on IBR than what would have been paid
under the 10-year standard repayment plan (called “partial financial
hardship”)
• Pay As You Earn
– Direct Loan borrowers with eligible loans
– Must be new borrower on/after 10/1/2007 who received new loan
on/after 10/1/2011, and
– Their payments would be lower on Pay As You Earn than what would
have been paid under the 10-year standard repayment plan (called
“partial financial hardship”)
Eligible Loans
• ICR
– All Direct Loans are eligible except parent PLUS Loans and pre7/1/2006 Direct Plus Consolidation Loans
– Direct Consolidation Loans made on/after 7/1/2006 that repaid
parent PLUS loans are eligible
• IBR
– All Direct and FFEL Program loans except parent Plus loans and
Consolidation Loans that repaid parent PLUS loans
• Pay As You Earn
– All Direct Loans are eligible except parent PLUS loans and
Consolidation Loans that repaid parent PLUS loans
Payment Amounts
• Under ICR, borrowers pay the lesser of
– 12-year standard repayment schedules multiplied by income percentage
–
factor (payment based on loan debt and income), or
20% of discretionary income (payment based only on income)
• IBR
– 15% of discretionary income (income-based payments), or
– What the would have paid under the 10-year standard repayment plan (nonincome-based payments)
• Pay As You Earn
– 10% of discretionary income (income-based payments), or
– What they would have paid under the 10-year standard repayment plan
(non-income-based payments)
Interest Subsidy Benefit
• IBR and Pay As You Earn only
• Borrower eligible when payment does not cover accruing interest on
subsidized loans (negative amortization)
• Eligibility limited to first 3 consecutive years of repayment under plan
• Subsidy amount (paid by ED) = accruing interest on subsidized loans
not covered by monthly payment
– Borrower must pay all interest on unsubsidized loans
• Interest subsidy eligibility period continues:
– During deferment/forbearance, except during periods of economic hardship
–
–
deferment
During periods when borrower doesn’t qualify for subsidy (monthly payment
covers accruing interest), and
If borrower switches from IBR to Pay As You Earn, or vice versa
Capitalization
• ICR
– During periods of negative amortization, annually
– Interest capitalizes only until principal balance is 10% greater than original principal
from when borrower entered repayment
Otherwise, normal capitalization on rules apply
•
–
IBR
– No longer qualifies for payments based on income (no longer has a partial financial
hardship) or
Leaves IBR entirely
•
–
Pay As You Earn
– No longer qualifies for payments based on income (no longer has a partial financial
–
–
hardship) or
Leaves Pay As You Earn entirely
Interest capitalizes only until principal balance is 10% greater than original principal
amount when borrower entered plan
Loan Forgiveness
• All three plans provide for forgiveness
• For ICR and IBR, remaining balance forgiven after 25 years
•
•
of qualifying repayment
For Pay As You Earn, remaining balance forgiven after 20
years of qualifying repayment
For all three plans, qualifying repayment includes:
– Payments under an income-driven plan
– Payments under the 10-year standard repayment plan (or any other
–
repyament plan with a payment amount at least equal to the 10-year
standard plan amount), or
Economic hardship deferment
• According to the IRS, the forgiven amount is considered
taxable income (see IRS Publication 4681)
Borrower Example
• Danny N. Debt:
– Is single with no dependents and lives in New York;
– Has an AGI of $35,000; and
– Has $50,000 in Direct Loan debt ($23,000 of which is
subsidized), all of which has a 6.8% interest rate
ICR Example Borrower
• Under ICR, Danny will*:
– Have an initial monthly payment of $397.17
– Have a final monthly payment of $535.23
– Make payments that cover all accruing interest, and therefore not
have annual capitalization
– Pay off his loans in 164 months (13 years, 8 months), and therefore
receive no forgiveness
– Pay a total of $78,444.28 on his $50,000 loan debt, compared to:
• $69,037.44 under the 10-year Standard Repayment Plan or
• $104, 080.83 under the Extended Plan or Consolidation Standard Plan
* Assumes a 5% increase in Danny’s income each year and a 3% annual increase
in the poverty guidelines.
IBR Example Borrower
• Under IBR, Danny will*:
– Have an initial monthly payment of $228.06
– Have a final monthly payment of $575.40
– Receive $653.16 in interest subsidy during the first three consecutive
years of IBR repayment (because the payment will not cover all accruing
interest on subsidized loans)
– Have a payment that is no longer based on his income (no longer have
a partial financial hardship) in his 16th year of IBR
– Pay off his loan at the beginning of his 21st year of IBR and therefore
receive no loan forgiveness
– Pay a total of $101,673.34 on his $50,000 loan debt, compared to
• $69,037.44 under the 10-year Standard Repayment Plan or
• $104, 080.83 under the Extended Plan or Consolidation Standard Plan
* Assumes a 5% increase in Danny’s income each year and a 3% annual increase in the
poverty guidelines.
Pay As You Earn Example Borrower
• Under Pay As You earn, Danny will*:
– Have an initial monthly payment of $152.04
– Have a final monthly payment of $492.19
– Receive $1,999.789 interest subsidy during all of the first three
consecutive years of Pay As You Earn repayment (because the monthly
payment will not cover all accruing interst on subsidized loans)
– Always have a payment that is based on his income (will always have a
partial financial hardship)
– Receive forgiveness in the amount of $44,979.06
– Pay a total of $70,709.53 on his $50,000 loan debt, compared to:
• $69,037.44 under the 10-year Standard Repayment Plan or
• $104, 080.83 under the Extended Plan or Consolidation Standard Plan
* Assumes a 5% increase in Danny’s income each year and a 3% annual increase in the
poverty guidelines.
Borrower Examples
ICR
IBR
Pay As You Earn
Initial Payment
$397.17
$228.06
$152.04
Final Payment
$535.23
$575.40
$492.19
Time Repayment
13 years, 8 months 20 years, 2 months 20 years
Total Paid
$78,444.28
$101,673.34
$70,709.53
Forgiveness
$0
$0
$44,979.06
10-year Standard
Extended & consolidation
Standard
Payment
$575.40
$347.04
Time in Repayment
10 years
25 years
Total Paid
$69,037.44
$104,080.83
PUBLIC SERVICE
LOAN FORGIVENESS
Public Service Loan Forgiveness
• Public Service Loan Forgiveness (PSLF) provides for
forgiveness of Direct Loan borrower’s remaining loan balance
if the borrower:
– Makes 120 full, on-time payments after 10/ 1/2007
– Makes each payment under a qualifying repayment plan
– Makes each payment while employed full-time by a qualifying
organization
• Borrower must also be employed by qualifying organization at
time borrower applies for & receives PSLF
• According to the IRS, the forgiven amount is not treated as
taxable income
PSFL Qualifying Payments
• Borrower must make 120 separate monthly payments. They:
– Do not need to be consecutive
– Must be for the full scheduled payment under the repayment plan
– Must be made within 15 days of the due date
• Multiple, partial payments during the borrower’s monthly billing cycle
will qualify if they add up to equal the borrower’s monthly payment
amount
• A borrower will not receive credit for more than one payment toward
PSLF if the borrower makes a lump sum payment (e.g., makes a
single payment equal to two or more full monthly payments)
– Exception for AmeriCorps and Peace Corps borrowers who make lump
sum payments using education award or transition payment
Relation Between PSLF and
Income-Driven Plans
• Remember Danny N. Debt? He didn’t qualify for IBR or
ICR forgiveness
• Many borrowers with interest in income-driven plans are
like Danny
• Unless their debt-to-income ratios remain unbalanced for a long
period of time, no forgiveness
• For borrowers like Danny:
• An income-driven plan can provide the benefit of a lower
payment and
• PSLF can help avoid the trade off of paying substantially more
than the standard plan over the life of the loan
PSLF Borrower Example
• Danny N. Debt was single with no dependents and
resides in Connecticut
• Danny has $50,000 in Direct Loans and an AGI of
$35,000
• Danny’s income increases by 5% a year, and the poverty
guidelines increase by 3% a year
• Though he did not qualify for IBR or ICR forgiveness, if
he works in qualifying employment, he will qualify for
PSLF
PSLF borrower Example
Without PSLF
ICR
IBR
Pay As You Earn
Time in Repayment 13 years, 8 months 20 years, 2 months 20 years
Total Paid
$78,444.28
$101,673.34
$70,709.53
Plan Forgiveness
$0
$0
$44,979.06
With PSLF
ICR
IBR
Pay As You Earn
Time in Repayment 10 years
10 years
10 years
Total Paid
$55,952.61
$37,222.34
@24,814.89
Plan Forgiveness
$19,858.58
@45,711.82
$57,189.97
EDUCATING BORROWERS:
WHAT YOU NEED TO KNOW
Counseling Students on
Income-Driven Plans
• Familiarize your students with NSLDS. Encourage them to review
•
•
•
•
•
their portfolio. How many loans? Amounts? Number of Servicers?
Borrowers need solid understanding/communication with servicer
– Who & Options for assistance
Help them understand ALL options, as IDRs may not always fit
Borrowers must request IDR and provide their 1040 Tax form or alt
doc income form – complete, accurate, and signed
Remind borrowers to renew their plan on yearly basis; while a PFH
payment is low, there could be a higher payment applied in the
future, should they no longer qualify for PFH
Schools can promote internal/external IDR resources & tools
Questions?
Dana Kelly
Nelnet National Trainer and Regional Director
336.848.6441 (office)
[email protected]
Anne Del Plato
Nelnet Regional Director for New York
518.285.6236
[email protected]
www.NelnetLoanServicing.com

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